OCC Proposes Formal Guidelines for Heightened Expectations for Large Banks

The Office of the Comptroller of the Currency (“OCC”) released a proposal setting forth new standards for large national banks and federal savings associations that would be enforceable under Part 30 of its regulations.  The guidelines set forth the minimum standards for the design and implementation of an institution’s risk governance framework and provide minimum standards for oversight of that framework by the board of directors. 

The new standards are based on the OCC’s heightened expectations program, which was developed by the agency following the financial crisis to strengthen the governance and risk management practices of large national banks and federal savings associations, as well as to enhance the OCC’s supervision of those institutions.

The proposed guidelines would apply to any insured national bank, insured federal savings association or insured federal branch of a foreign bank, with average total consolidated assets of $50 billion or more. The proposal would reserve the OCC’s authority to apply the guidelines to an institution with less than $50 billion in assets if the OCC determines that it is highly complex or otherwise presents a heightened risk.

See: Notice of Proposed Rulemaking; OCC Press Release


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